ML20135C365
| ML20135C365 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/21/1997 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1600 IEIN-96-017, IEIN-96-17, TXX-97049, NUDOCS 9703030527 | |
| Download: ML20135C365 (4) | |
Text
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Log # TXX 97049 F%
File # 10010
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February 21, 1997 1UELECTRIC' C. Lance Terry Group %cr President U. S. Nuclear Regulatory Commission Attn: Document Control Desk 1
Washington, DC 20555
SUBJECT:
Initiatives for Identifying and Correcting FSAR Discrepancies REF:
1)
NRC Information Notice 96 17. " Reactor Operation Inconsistent with the Updated Final Safety Analysis Report" 2)
CPSES 9603281 May 28, 1996, "CPSES Action Plan Regarding the Information Notice Concerning Hillstone Compliance with the FSAR/ Licensing Basis Documents" 3)
NRC SECY-96154 July 5,1996 " Proposed Revision to Enforcement Policy NUREG 1600, Enforcement Guidance for Departures from the FSAR..."
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4)
Federal Register Notice Vol. 61. No. 203/ October 18, 1996 " Policy and Procedure for Enforcement Actions:
Departures from FSAR" 5)
TXX 96508 November 13, 1996," PROPOSED ENGINEERING SELF-ASSESSMENT" 6)
CPSES 9607752 December 19, 1996 "NEI Initiative for Assessing Programs for Maintaining the Licensing Basis" 7)
N0E EVAL 96 000188, December 20, 1996, "CPSES Industry Initiative on Maintaining the Licensing Basis..."
8)
CPSES 9700017 January 15, 1997 " Initiatives for Identifying and Correcting FSAR Discrepancies" 9)
TXX-97001 February 7, 1997, " RESPONSE TO REQUEST FOR INFORMATION PURSUANT TO 10CFR50.54(f)REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION."
This letter confirms and makes publicly available the voluntary initiatives that are in progress and will be completed by October 18, 1928 to identify and correct FSAR discrepancies. If generic issues are identifit.'i, the scope of the initiative will be appropriately expanded to identify ano address other potential failures with similar root causes. References 2, 6, 7, and 8 are available onsite for your review as necessary.
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4 TXX 97049 Page 2 of 4 NEI Initiative a
Reference 6 defines the CPSES plan and schedule for completion of the NEI initiative to perform self assessments of the adequacy of programmatic controls for maintaining the Licensing Basis in order to identify missing or incorrectly applied programmatic elements that can lead to Licensing Basis differences, and to communicate the results of the assessment to NEI in writing by 4/15/97.
NEI will compile the overall industry results to assess the composite adequacy and effectiveness of programs designed to maintain the Licensing Basis of the plants. The overall industry results will be reported to the NRC by NEI.
This NEI initiative specifically requires the plants to: a) conduct an assessment of programs curren'ly in use to ensure the plant is operated in c
4-conformance with its licensing basis using NEI 96 05. " Guidelines for Assessing Programs for Maintaining the Licensing Basis," or other approaches that provide an equivalent scope of review, b) assess the i
accuracy of the FSAR descriptions for two safety-related systems and two nonsafety related systems determined to be " risk significant" per the i
maintenance rule as described in step 3.1.1 of NEI 96 05, c) ensure any j
identified non conforming or degraded conditions are captured on a tracking i
system and resolved in a timely manner, and d) communicate the results of i
the assessment to NEI in writing by 4/15/97 using the report format in the NEI 96 05 initiative guidance document, dated 10/07/96.
Part "a" of the initiative has been completed and is documented in reference 7.
Part "b" is nearing completion of the reviews for the four systems selected (Station Service Water, Emergency Diesel Generators, Instrument Air and Switchyard). A high percentage of the FSAR statement reviews were evaluated by the recent Engineering Self Assessment, the scope of which is defined in reference 5.
Any discrepancies are being dowme ited and addressed as required. The overall results of the assessments for parts "a" and "b" will be documented in the final report to NEI.
FSAR Review by System Enaineers The system engineers will review the applicable sections of the FSAR that relate to their areas of responsibility, and will complete and document these reviews by October 18. 1998. Any discrepancies will be documented and addressed as required. The primary purpose of this review will be to reconfirm that the as built configuration and design documentation of their individual systems and structures are consistent with the FSAR descriptions and the accident analysis assumptions in Chapter 15 of the FSAR.
NOD Planned Evaluations As discussed in reference 2, which identified actions being taken regarding reference 1, the Nuclear Overview Department is including a review of the applicable portions of the FSAR as part of their current ongoing evaluations. A discussion of the FSAR findings is specifically included in the issued reports. Any discrepancies will be documented and addressed as required.
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j TXX 97049 Page 3 of 4 3
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FSAR Ouestion and Response (0 & Rs) Reviews I
TU Electric will coordinate a review of those Q & Rs rolled into the FSAR i
j to assure that those Q & Rs requiring review external to Regulatory Affairs
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i prior to being incorporated into the FSAR were properly executed. These l
reviews will be completed and documented by October 18. 1998. Any l
discrepancies will be documented and addressed as required.
l Tech Soec Conversion 5
As part of the Tech Spec conversion process to the new standard Tech Specs, certain requirements will be moved from the Tech Specs to other Licensing Basis Documents (LBDs). TU Electric will coordinate reviews of those 4
j related sections of.the LBDs to assure their consistency with the plant.
These reviews will be completed consistent with the Tech Spec conversion implementation schedule. Any discrepancies will be documented and addressed as required.
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Onacina FSAR and LBD Chance Process Reviews The program for updating the FSAR requires an individual identifying the need for a change to obtain a License Document Chi.nge Request (LDCR) i tracking number when they become aware of a potential need for a revision.
Additionally, potentially deficient conditions related to LBD discrepancies are documented as discussed in reference 9 attachment 2.
The procedures which control the change processes (procedure changes, design-modifications, etc.) require a 50.59 review (LBD review) and, if required, an LDCR is initiated in accordance with the procedures. The LDCRs are the vehicle for making the changes.
l Proposed changes are reviewed along with the associated activity as required by the CPSES 10CFR50.59 review program and are forwarded to the CPSES Regulatory Affairs Department for incorporation.
Prior to j
incorporation. Regulatory Affairs conducts reviews of other Licensing Basis Document (LBD) manuals to assure that consistency will be maintained upon incorporation of a change. -Commitments are also captured as required for tracking to assure continued compliance.
Furthermore, additional technical reviews may be conducted to further assure that specific changes accurately reflect CPSES activities. A page by page description is prepared and submitted to the NRC with each FSAR amendment. These ongoing programs will also help assure the accuracy of the FSAR.
NRC Enforcement Policy for Denartures from the FSAR As discussed in references 3 and noticed in reference 4. the Enforcement Policy was amended to address issues associated with departures from the FSAR. This revision to the Enforcement Policy became effective when issued on October 18, 1996, and provides a two year period of enforcement discretion on FSAR departures for licensees with voluntary initiatives for reviewing their FSARs. These changes to the Enforcement Policy were intended to " provide incentives to encourage licensees to identify and correct violations which are not normally identified through current
j TXX 97049 i
Page 4 of 4 survei11ance and qual 1ty assurance actiV1 ties. " This new poiicy states i
that " Enforcement action would normally not be taken against a licensee if j
the licensee identifies violations up to and including Severity Level II associated with the FSAR by a voluntary initiative (including either a formal program or informal effort where issues are identified through a i
questioning attitude of an employee), provided the licensee takes comprehensive corrective action and appropriately expands the scope of the voluntary initiative to identify other failures with similar root causes.
i If this enforcement discretion is utilized, the licensee's voluntary i
initiative must be described in writing and be publicly available.
The staff will reference and sumarize the licensee's voluntary initiative, including the scope and schedule for the corrective action, in an j
inspection report and will follow the licensee's corrective action until complete as an inspection report opEn item." It should be noted that there are some exceptions to this enforcement discretion. One example specifically related to the initiatives where discretion would not normally be app 11ed is when the "NRC identifies the violation unless it was likely in the staff's view that the licensee would have identified the violation in light of the defined scope, thoroughness, and schedule of the licensee's initiative."
We believe that the CPSES initiatives meet the definition of the voluntary initiatives discussed by the new NRC Enforcement Policy. Therefore, we request that the staff consider our initiatives for potential enforcement discretion as allowed by the Enforcement Policy prior to issuing violations related to FSAR cepartures. The initiatives docketed by this letter are also summarized in reference 8, which has been previously reviewed with the CPSES Senior Resident inspector by members of our staff.
Sincerely, 0 h.
C. L. Terry 97 7 N -
By:
R. D. Walker Regulatory Affairs Manager TAH/th c-Mr. J. E. Dyer, Region IV Mr. J. I. Tapia, Region IV Mr. T. J. Polich, NRR Resident Inspectors, CPSES